International

  • May 27, 2024

    EU Flags 6 Countries For Failures On Transparency Law

    The European Commission flagged six countries for deficiencies in its implementation of an EU law requiring some companies to publish their tax data, the EU's executive said in a news release. 

  • May 27, 2024

    Fiji Joins International Framework Against Tax Avoidance

    Fiji joined an international group of jurisdictions aiming to stop tax avoidance, the Organization for Economic Cooperation and Development said Monday, adding that the country would participate in the two-pillar solution to change tax rules for large multinational companies.

  • May 24, 2024

    Court Upholds Limit To Award In Ecopetrol, Texas Co. Dispute

    An arbitration tribunal was within its authority to limit the number of years and the amount that a Houston-based oil company had to reimburse Colombia's state-owned entity, Ecopetrol, for the value-added tax liability of a subsidiary while owned by the company, a New York federal judge determined.

  • May 24, 2024

    CohnReznick Adds Tax Planning Partner From Mazars

    CohnReznick LLP added a top accountant and tax partner from Mazars USA LLP to its roster of tax professionals, the firm announced.

  • May 24, 2024

    Global Minimum Tax Should Be Tied To Inflation, Report Says

    The €750 million ($814 million) annual revenue threshold for businesses to be considered in scope of the OECD's global corporate minimum tax should be indexed to inflation to protect businesses from being wrongly forced to comply, a think tank report said.

  • May 24, 2024

    UK Calls On Belarus To Undo Suspension Of Tax Agreement

    The U.K. is demanding that Belarus reverse a council resolution that suspends provisions of the double-taxation agreement between the two countries starting June 1, according to a statement released by HM Revenue & Customs.

  • May 24, 2024

    IRS Corrects Notice On Bonus Energy Tax Credit Safe Harbors

    The Internal Revenue Service and U.S. Department of the Treasury issued a correction Friday to a notice providing additional safe harbors that clean energy project developers can use to qualify for bonus tax credits for domestically sourcing their steel and aluminum parts.

  • May 24, 2024

    €14M VAT Fraud Scheme In Belgium, Netherlands Busted

    Seven people were arrested in the Netherlands in connection to a value-added tax fraud scheme involving the Belgian subsidiary of a Dutch company fraudulently claiming a €13.7 million ($14.9 million) refund on trades of goods that never happened, the European Public Prosecutor's Office said Friday.

  • May 24, 2024

    EU Withholding Tax Deal Lacks Ambition, Investors Say

    A recently agreed-to streamlining of how cross-border withholding taxes are refunded in the European Union lacks ambition and may not do much to help smaller investors, investor advocates said.

  • May 24, 2024

    Taxation With Representation: Davis Polk, Wachtell, Latham

    In this week's Taxation With Representation, SouthState Corp. buys Independent Bank Group Inc., CyberArk acquires Venafi, Carlyle clinches its fifth Japanese buyout fund, and AuditBoard Inc. agrees to be bought by Hg Capital.

  • May 24, 2024

    Cyprus, Portugal Aim For National Implementation Of Pillar 2

    Cyprus and Portugal both said Friday that they are moving toward putting the minimum tax known as Pillar Two into their national legislation, which EU law requires them to have done by the end of 2023.

  • May 23, 2024

    Premier League Team Goes Down 2-Nil In VAT Bill Appeal

    Premier League soccer team Nottingham Forest must pay its more than £345,000 ($438,000) value-added tax bill, the U.K.'s Upper Tribunal ruled in a decision published Thursday, dismissing an appeal of a lower court ruling that found HM Revenue & Customs filed its tax assessment on time.

  • May 23, 2024

    Italy Adopts Safe Harbor Global Minimum Tax Rules

    Italy has added a temporary safe harbor provision to its implementation of the Organization for Economic Cooperation and Development's global minimum tax to ease the transition for in-scope companies, the country's finance ministry said.

  • May 23, 2024

    White & Case Adds Former A&O Tax Pro In Luxembourg

    White & Case LLP announced it has added a tax partner to its Luxembourg office from A&O Shearman who specializes in international and Luxembourg corporate tax law.

  • May 23, 2024

    Carbon Pricing Generated Over $100B In 2023, Report Says

    Carbon pricing mechanisms worldwide generated a record $104 billion in revenue in 2023, according to a World Bank report, though it said the 75 instruments currently in force are too few and doing too little.

  • May 23, 2024

    Spain, Greece, Sweden Have Tax Policy Problems, EU Says

    The European Union's executive arm called on Spain, Greece and Sweden on Thursday to change tax laws the bloc finds problematic, while also referring a Spanish tax issue to the European Court of Justice.

  • May 23, 2024

    EU Flags Nations For Shortcomings On Pillar 2, Exchange Law

    The European Commission said Thursday that six European Union countries still have failed to implement the global minimum tax for large companies, and it noted that an additional three aren't properly implementing an information exchange law.

  • May 23, 2024

    Yellen Opposes Global Redistribution Of Billionaires' Wealth

    U.S. Treasury Secretary Janet Yellen repeated Thursday that she opposes a global minimum tax on billionaires and added that she does not support basing a redistribution of the revenue from such a tax on damage from climate change and related financing needs.

  • May 23, 2024

    G7 Should Agree On Frozen Russian Assets, Yellen Says

    U.S. Treasury Secretary Janet Yellen said Thursday that the Group of Seven countries should agree now on a concept of how the capital of frozen and immobilized Russian state assets should be used to support Ukraine's war against Russia.

  • May 23, 2024

    EU Could Add Sectors To Border Tax, Commissioner Says

    The European Union should consider expanding its carbon border tax beyond the initial sectors covered, an EU commissioner has said.

  • May 23, 2024

    Akerman Brings On Kilpatrick Tax Ace In LA

    Akerman LLP is boosting its tax team, bringing in a Kilpatrick Townsend & Stockton LLP corporate tax and energy tax credit expert as a partner in its Los Angeles office.

  • May 22, 2024

    Justices' CFPB Alliance May Save SEC Courts, Not Chevron

    A four-justice concurrence to the U.S. Supreme Court's decision upholding the Consumer Financial Protection Bureau's unique funding scheme last week carries implications for other cases pending before the court that challenge the so-called administrative state, or the permanent cadre of regulatory agencies and career government enforcers who hold sway over vast swaths of American economic life.

  • May 22, 2024

    German Legislature Moves To Update Certain Tax Treaties

    The lower house of Germany's legislature has approved a bill to update multiple bilateral tax treaties as part of the country's implementation of the Organization for Economic Cooperation and Development's project against base erosion and profit shifting.

  • May 22, 2024

    Doctor Must Stay In Jail In Tax Penalty Fight, Gov't Says

    A doctor incarcerated for civil contempt for not paying $1.1 million in penalties for failing to report his foreign accounts should remain in jail until he has done more to comply, the U.S. government told a Michigan federal court Wednesday.

  • May 22, 2024

    Belgium Provides Pillar 2 Reporting Rules

    Belgium's finance ministry has issued guidance on what large multinational entities and domestic groups will need to do to comply with the country's coming registration requirement as part of its implementation of the Organization for Economic Cooperation and Development's global corporate minimum tax.

Expert Analysis

  • Attorneys, Law Schools Must Adapt To New Era Of Evidence

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    Technological advancements mean more direct evidence is being created than ever before, and attorneys as well as law schools must modify their methods to account for new challenges in how this evidence is collected and used to try cases, says Reuben Guttman at Guttman Buschner.

  • 1st Tax Easement Convictions Will Likely Embolden DOJ, IRS

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    After recent convictions in the first criminal tax fraud trial over allegedly abusive syndicated conservation easements, the IRS and U.S. Department of Justice will likely pursue other promoters for similar alleged conspiracies — though one acquittal may help attorneys better evaluate their clients' exposure, say Bill Curtis and Lauren DeSantis-Then at Polsinelli.

  • Tips For Litigating Against Pro Se Parties In Complex Disputes

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    Litigating against self-represented parties in complex cases can pose unique challenges for attorneys, but for the most part, it requires the same skills that are useful in other cases — from documenting everything to understanding one’s ethical duties, says Bryan Ketroser at Alto Litigation.

  • Anticipating Intensified Partnership Enforcement From IRS

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    The Internal Revenue Service's decadeslong difficulties with partnership audits led to the recent announcement of a clear, well-funded, focused initiative, and businesses operating in the partnership form will feel the impact, with definite changes ahead, says Sharon Katz-Pearlman at Greenberg Traurig.

  • Pro Bono Work Is Powerful Self-Help For Attorneys

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    Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.

  • The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'

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    The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.

  • How And Why Your Firm Should Implement Fixed-Fee Billing

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    Amid rising burnout in the legal industry and client efforts to curtail spending, pivoting to a fixed-fee billing model may improve client-attorney relationships and offer lawyers financial, logistical and stress relief — while still maintaining profit margins, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • How Law Firms Can Use Account-Based Marketing Strategies

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    Amid several evolving legal industry trends, account-based marketing can help law firms uncover additional revenue-generating opportunities with existing clients, with key considerations ranging from data analytics to relationship building, say Jennifer Ramsey at stage LLC and consultant Gina Sponzilli.

  • Strategic Succession Planning At Law Firms Is Crucial

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    Senior partners' reluctance to retire, the rise of the nonequity partner tier and generational differences in expectations are all contributing to an increasing number of departures from BigLaw, making it imperative for firms to encourage retirement among senior ranks and provide clearer leadership pathways to junior attorneys, says Laura Leopard at Leopard Solutions.

  • Maximizing Law Firm Profitability In Uncertain Times

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    As threats of an economic downturn loom, firms can boost profits by embracing the power of bottom-line management and creating an ecosystem where strategic financial oversight and robust timekeeping practices meet evolved client relations, says Shireen Hilal at Maior Strategic Consulting.

  • 5th Circ. Ruling Reminds Attys That CBP Can Search Devices

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    The Fifth Circuit’s recent Malik v. Department of Homeland Security decision adds to the chorus of federal courts holding that border agents don’t need a warrant to search travelers’ electronic devices, so attorneys should consider certain special precautions to secure privileged information when reentering the U.S., says Jennifer Freel at Jackson Walker.

  • Enforcement Of International Tax Reporting Is Heating Up

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    Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.

  • IRS Notice Clarifies R&E Amortization, But Questions Remain

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    The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.

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